Archive

CFPB ISSUES FCRA ADVISORY OPINION

On July 7, the Consumer Financial Protection Bureau (CFPB) published a legal interpretation to ensure that companies that use and share credit reports and background reports have a permissible purpose under the Fair Credit Reporting Act (FCRA). The CFPB’s new advisory opinion makes clear that credit reporting companies and users of credit reports have specific obligations to protect the public’s data privacy. The advisory also reminds covered entities of potential criminal liability for certain misconduct. […]

CFPB CRITICAL OF CREDIT BUREAU PROCEDURES

On November 4, 2021, the Consumer Financial Protection Bureau published a sixteen-page advisory opinion to highlight that a consumer reporting agency that uses inadequate matching procedures to match information to consumers, including name-only matching (i.e., matching information to the particular consumer who is the subject of a consumer report based solely on whether the consumer’s first and last names are identical or similar to the names associated with the information), in preparing consumer reports (for […]

REPORT RENTAL INFORMATION ACCURATELY

On July 1, 2021, the Consumer Financial Protection Bureau (CFPB) released an Enforcement compliance bulletin reminding landlords, consumer reporting agencies (CRAs), and others of their critical obligations to accurately report rental and eviction information. Inaccurate rental and eviction information on a tenant screening report or a credit report can unfairly block a family from safe and affordable housing. As the federal eviction moratorium and other pandemic rental protections come to an end, the CFPB wants […]

FCRA REVISIONS UNDER WAY

On August 24, 2020 the Federal Trade Commission (FTC) issued a Notice of Proposed Rulemaking (NPRM) that would update several rules contained in the Fair Credit Reporting Act (FCRA) with provisions contained in the Dodd-Frank Act. It is important to consider that rules under the FCRA that impact auto dealers are issued by the FTC. FCRA rules that impact financial institutions are issued by the Consumer Financial Protection Bureau. The FTC issued five separate NPRMs […]

CARES ACT IMPACT ON CREDIT REPORTING

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) became law on March 27, 2020. On April 1, 2020 the Consumer Financial Protection Bureau (CFPB issued a statement of policy on Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act. The statement highlights furnishers’ responsibilities under the CARES Act and inform consumer reporting agencies and furnishers of the CFPB’s flexible supervisory and enforcement approach […]